Com. v. Williams, R.
Com. v. Williams, R. No. 638 EDA 2016
| Pa. Super. Ct. | Apr 17, 2017Background
- Appellant Raymond V. Williams pled guilty to first-degree murder and rape on April 7, 2005 and was sentenced to life imprisonment without direct appeal.
- Williams first filed a habeas corpus petition in 2012; the PCRA court treated it as untimely and dismissed it, with an appeal later withdrawn.
- On February 27, 2013, Williams filed another habeas petition, this time against the SCI Graterford Superintendent, alleging illegal detention due to the absence of a written sentencing order; an amendment followed on May 21, 2014.
- In November 2015, the trial court, treating the petition as a PCRA petition, issued a Rule 907 notice of dismissal as untimely; Williams answered December 3, 2015; the court dismissed on January 15, 2016.
- The court acknowledged error in labeling the petition as an untimely PCRA petition but held the claim lacked merit; Williams timely appealed on February 12, 2016.
- On appeal, the Superior Court held that while the petition was not properly a PCRA filing, the underlying claim was not cognizable and must be denied for lack of remedy under existing law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the habeas petition was improperly deemed a PCRA petition | Williams argues the court erred in treating the petition as untimely PCRA. | Court treated petition as PCRA for procedural purposes and dismissed as lacking merit. | The court acknowledged the mislabeling but affirmed dismissal on substantive grounds. |
| Whether the petition alleges a cognizable habeas claim within the applicable framework | Williams contends the claim is a valid habeas challenge to detention due to missing sentencing order. | Claim is not cognizable; issues related to sentence legality fall under PCRA or are not proper habeas grounds. | Claims are not cognizable; remedy is limited by Joseph and related precedents. |
| Whether the absence of a written sentencing order invalidates detention under existing law | Detention may be illegal due to lack of a sentencing order and DOC authority under 37 Pa. Code § 91.3 and 42 Pa.C.S.A. § 9764. | Section 9764 does not create a DOC obligation to produce documents or a remedy for the inmate; transfer procedures govern. | DO C authority is not defeated by absence of a sentence order; remedy not provided; petition properly denied. |
Key Cases Cited
- Commonwealth v. Judge, 916 A.2d 511 (Pa. 2007) (limits habeas scope to exceptional circumstances consistent with PCRA)
- Joseph v. Glunt, 96 A.3d 365 (Pa. Super. 2014) (habeas claim regarding inability to produce a sentencing order can be cognizable)
- Commonwealth v. McNeil, 665 A.2d 1247 (Pa. Super. 1995) (habeas corpus is a civil remedy available for commitments within criminal process)